Office of Foreign Assets Control

News & Analysis as of

US Issues Crimea Sanctions Advisory, Designates Additional Russian and Ukrainian Individuals and Entities

On July 30, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a Crimea Sanctions Advisory, identified certain subsidiaries of entities included on the Sectoral Sanctions Identifications...more

Limited Access to Cuba but it is a Start for U.S. Businesses

As you know there are ongoing changes to the Cuba export regulations. President Obama announced the reopening of the U.S. embassy in Havana and a Cuban embassy in Washington. The Commerce Department will remove Cuba from list...more

White House Hostage Policy Leaves Risk on Table for Third Parties

Last month, the White House announced a change in its policy toward overseas hostage-takings of U.S. citizens. The new policy, accompanied by an Executive Order, aims to effect policy changes at home and overseas, including a...more

Cuba Si! Trade With Cuba … Not Quite Yet

There has been much fanfare surrounding the reestablishment of diplomatic relations with Cuba, starting with President Obama’s announcement of the resumption of bilateral relations, and followed by the formal establishment of...more

OFAC Publishes Venezuela Sanctions Regulations

On July 10, OFAC published regulations to implement the Venezuela Defense of Human Rights and Civil Society Act of 2014 and Executive Order 13692. The Act required the President to impose targeted sanctions on certain persons...more

Iran – Don’t Forget the General License!

Iran entered into a historic nuclear agreement with the U.S. and other world powers on July 14th 2015. The agreement will allow the licensing of the export, re-export, sale, lease or transfer to Iran of commercial passenger...more

Ten Key Elements of an AML Compliance Program

AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of...more

Potential Upstream Investment Under the New Iranian Petroleum Contract

The signing of the JCPOA regarding Iran nuclear sanctions may usher in a new era of major international investment in the Iranian oil and gas industry....more

Finalized Iran Nuclear Deal Outlines Changes for U.S. and EU Sanctions

On July 14, 2015, negotiators from Iran, the EU, and the P5+1 countries —China, France, Russia, the United Kingdom, the United States, and Germany—announced that they had reached a consensus on the final text of the Joint...more

OFAC Provides Overview of Agreement with Iran Regarding Sanctions Relief

On July 14, OFAC released a statement regarding the agreement reached with Iran over its nuclear program. Following months of diplomacy, OFAC stated that the P5 + 1 reached a Joint Comprehensive Plan of Action (JCPOA) with...more

The Times Are Changing, But Very Slowly

First, we learned relations with Cuba were thawing, and now – on July 14th – there is the nuclear deal with Iran. Many American companies are clambering to make commercial deals with businesses in both countries – but not so...more

Orrick's Policyholder Insider Quarterly

Five Lessons Health Care Companies Should Learn From Cyberattacks - The American health care industry is under attack by sophisticated hackers seeking access to electronic medical records. Since January, three health...more

Vienna Deal Brings Iran In From The Cold

After months of wrangling, a deal has finally been reached allowing Iran to develop a peaceful domestic nuclear programme with the lifting of economic and financial sanctions.This is on the strict proviso that Iran does not...more

"Sanctions Relief Under the P5+1 Agreement With Iran: Implications for US, EU and International Business"

On July 14, 2015, the P5+1 (the United States, the United Kingdom, France, China, Russia and Germany) along with the European Union reached a historic agreement with Iran, called the Joint Comprehensive Plan of Action (the...more

A Tale Of Trade And Trademarks: General Cigar Co., Inc. v. Empresa Cubana Del Tabaco

The United States has taken several recent steps towards normalizing its ties with Cuba and, just yesterday, the two countries re-opened embassies in each other’s capitals for the first time since 1961. Despite these...more

Opportunity, Uncertainty for Entities Wishing to Do Business with Iran

Nuclear Deal with Iran Holds Out Possibility of Phased Relaxation of Sanctions - On July 14, 2015, the United States and five other countries (collectively known as the P5+11) reached a Joint Comprehensive Plan of...more

Iranian Nuclear Accord Reached, But Specific Implementation of Meaningful Sanctions Relief Will Not Be Immediate

On July 14, 2015, the “P5+1” nations (the United States, China, France, Germany, Russia, and the United Kingdom), together with the European Union and the Islamic Republic of Iran (“Iran”), reached a Joint Comprehensive Plan...more

Historic Agreement Reached with Iran—Iranian Nuclear Commitments in Exchange for Sanctions Relief

The Joint Comprehensive Plan of Action (JCPOA) - On July 14, 2015, following two years of negotiations, China, France, Germany, Russia, the United Kingdom, the United States and the European Union (referred to as P5+1 or...more

P5+1 Nations Reach Nuclear Deal with Iran

On July 14, 2015, the P5+1 nations (United States, United Kingdom, France, Russia, China and Germany) and Iran announced that they had agreed upon a Joint Comprehensive Plan of Action (JCPOA) regarding Iran’s nuclear program....more

Impact of Iran Accord on International Business - Briefing the "C" Suite on the Joint Comprehensive Plan of Action with Iran

On July 14, 2015, the United States, France, China, Russia, the United Kingdom, Germany and the European Union (EU) entered into the Joint Comprehensive Plan of Action (JCPOA) with Iran after years of difficult negotiations....more

US CHINA TRADE WAR JULY 2015 TPA, TPP, TRADE POLICY, TRADE AND CUSTOMS

Because of the substantial activity in May, June and July with the passage of Trade Promotion Authority (“TPA”) and the ongoing Trans Pacific Partnership (“TPP”) negotiations, this blog post is being split into two parts. ...more

A Break From the Past: Historic Deal with Iran Marks A New Day in U.S.-Iran Relations

Today, President Obama announced a landmark agreement with Iran designed to prevent Iran from obtaining a nuclear weapon in exchange for lifting sanctions that have retarded the country’s development for the decades since the...more

OFAC Issues Venezuela Sanctions Regulations

On July 10, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published, in abbreviated form, Venezuela Sanctions Regulations (VSR) in 31 C.F.R. Part 591. The VSR implement the Venezuela...more

Africa Update - July 2015 #2

In This Issue: - Leading the News - United States – Africa Relations - North Africa - East Africa - West Africa - Sub-Saharan Africa - General Africa News - Excerpt from Leading the...more

Trade & Manufacturing - July 2015

In This Issue: - Update on Trade Promotion Authority and Companion Trade Bills: A Lot Can Happen In Washington In 34 Days - Congress Allows Export-Import Bank Charter to Expire, for Now - WTO Finds That COOL Is...more

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